G.R. No. 188314 - People vs. Baharan

People of the Philippines, plaintiff-appellee; Gamal B. Baharan a.k.a. Tapay, Angelo Trinidad a.k.a. Abu Khalil, and Rohmat Abdurrohim a.k.a. Abu Jackie or Zaky, accused-appellants.
Appeal from the Court of Appeals Decision dated 30 June 2008 which affirmed the Regional Trial Court of Makati City Decision dated 18 October 2005 convicting the accused of multiple murder and multiple frustrated murder and sentencing them to death; the Court of Appeals modified the penalty to reclusion perpetua pursuant to Republic Act No. 9346.

On 14 February 2005 an RRCG bus was traveling southbound on EDSA from Navotas toward Alabang at about 6:30 to 7:30 p.m.
Two men ran after the bus at the Guadalupe-EDSA southbound stop and insisted on boarding; there were about 15 passengers aboard.
The bus conductor, Elmer Andales, observed the two men sit apart (one two seats behind the driver, the other at the back), noted reddish eyes of one, and grew suspicious when each paid for both passengers with PhP20.
The two repeatedly asked whether the bus would stop at Ayala Avenue; the rear passenger appeared to be tinkering with something hidden from view and glared when approached.
At the Ayala Avenue–EDSA stop the two insisted on alighting despite the driver’s initial reluctance under a Makati ordinance; they ran toward Ayala Avenue and moments later an explosion occurred, engulfing the bus in fire.
The bombing left four persons dead and more or less forty persons injured; Andales fled to a nearby mall and later returned and made a statement to the Makati Police Station.

Documents from the Department of Justice showed that shortly before the explosion the Abu Sayyaf Group spokesperson Abu Solaiman announced over DZBB radio that the group had a Valentine’s Day "gift" for former President Gloria Macapagal-Arroyo and later warned of more bomb attacks.
As stipulated, accused Trinidad and accused Baharan gave exclusive television interviews to ABS-CBN in which each admitted participation in the bombing.
As stipulated, accused Gappal Bannah Asali (Asali) gave a television interview admitting he supplied the explosive devices.

Conductor Elmer Andales identified accused Baharan and Trinidad as the two suspicious passengers who boarded and alighted shortly before the explosion.
Members of the Abu Sayyaf Group named as accused included Khaddafy Janjalani, Baharan, Trinidad, Gappal Bannah Asali, Jainal Asali, Rohmat Abdurrohim, and other John and Jane Does; only Baharan, Trinidad, Asali, and Rohmat were arrested; others remained at-large.
The arrested accused were charged with multiple murder (Crim. Case No. 05-476) and multiple frustrated murder (Crim. Case No. 05-477).

On arraignment for multiple murder, Baharan, Trinidad, and Asali entered pleas of guilty.
On arraignment for multiple frustrated murder, Asali pled guilty; Trinidad and Baharan initially pled not guilty; Rohmat pled not guilty to both charges.
The parties stipulated at pretrial to the following ten factual matters:

The court’s jurisdiction over the offenses.
That Baharan, Trinidad, and Asali knew one another before February 14, 2005.
That a bomb exploded in the RRCG bus while it was on EDSA fronting the MRT terminal in front of the Makati Commercial Center.
That Asali knew Rohmat, who taught him how to make explosive devices.
That Trinidad also admitted knowing Rohmat before the February 14 bombing.
That Baharan, Trinidad, and Asali admitted causing the bomb explosion which left four dead and about forty injured.
That Baharan and Trinidad each gave separate ABS-CBN interviews March 20–24 admitting participation.
That Trinidad and Baharan admitted pleading guilty because they were guilt-stricken after seeing a man carrying a child in the first bus they had entered.
That Asali admitted in mid-March giving a television interview admitting he supplied the explosive devices.
That Baharan, Trinidad, and ...(Subscriber-Only)

Whether the trial court committed reversible error by accepting the guilty pleas of Baharan and Trinidad without conducting a searching inquiry into voluntariness and comprehension as required by law.

First assignment of error by accused-appellants alleging insufficiency of the trial court’s searching inquiry at re-arraignment.

Whether the prosecution proved the guilt of accused-appellants beyond reasonable doubt.